Crediting Nutrient Discharges from Grey Infrastructure

Today’s Agenda Setting the Stage Basics About Nutrient Discharges The Expert Panel and Major Findings The Programmatic Credit Crediting Individual Nutrient Discharges

How Urban Land Cover is Represented in the Current Version of CBWM Impervious CoverPervious Cover Acres in Watershed 1 1,269,0303,398,732 Average TN Load 2 (lbs/ac/yr) Total (lbs/yr) 19,669, ,144, Acres as reported in most recent CBWM version Average values, as reported in Tetra Tech 2014a and ESC EP, 2014 (construction sites), although actual values are regionally variable

Major Findings Conclusive evidence that ND’s increase N and P levels in dry weather urban stream flow Dry weather NDs collectively account for as much as 20 to 40% of the annual nutrient load in urban watersheds, depending on the age and condition of its grey infrastructure. NDs comprise 1 to 2% of the total urban wet weather load, particularly during intense or extreme storms. 5

Elimination of Discovered Nutrient Discharges From Grey Infrastructure Findings: Expert Panel Final Report 6

Nutrient Discharges Refers to the complex range of non-stormwater flows that deliver nutrients into urban receiving waters during dry and/or wet weather caused by spills, leaks, and overflows from grey infrastructure. These discharges are created by: – the interaction of pollutant generating activities/sources – with aging grey infrastructure (sanitary sewers, drinking water pipes and storm sewers) – via stormwater runoff and groundwater migration.

Discovered Nutrient DischargeReported Nutrient Discharge Photo credit: The Washington Post

Discharge Detectives Need to use nutrient-based indicators during routine outfall screening Once a discharge is found, other discovery methods are needed to track it back to its source 9

Discharge Detective Work 10  Trained Sewage Sniffing Dogs  Flow Chart Method to Screen Small Diameter Pipes  GIS Analysis of Storm and Sewer Pipe Interactions  Sewer pipe flow metering  Continuous tracers in sewers  Nitrate Isotopes  Human Markers (e.g., caffeine)  Smoke and Dye Testing  CCTV Pipe Investigation

Credit for Advanced MS4 Nutrient Discovery Programs 11 AVAILABLE NOW!!

Program Credit Defined Annual credit equivalent to a maximum of 1% of the dry weather nutrient load within the jurisdiction, which in turn, is defined as 20% of the total annual N and P load discharged from the urban pervious land in which advanced nutrient reduction programs are targeted. = a 0.2% percent reduction in annual nutrient load discharged from urban pervious land targeted by the programs. 12

Qualifying Criteria for Advanced Programs The locality will provide justification to indicate that they are operating at an advanced level. At a minimum, they will document the following in their annual MS4 permit report: 13 1.Methods used to analyze dry weather stream monitoring data to prioritize the catchments and/or sewer- sheds with the highest risk for nutrient and bacteria discharge that warrant targeted investigation.

Qualifying Criteria for Advanced Programs 2.Number of outfalls in the priority catchments/sewer-sheds identified during the Outfall Reconnaissance Inventory (ORI) as described in (Brown et al 2004). 14

Qualifying Criteria for Advanced Programs 3.Number of outfalls in the priority catchments/sewer-sheds that were subject to nutrient testing, using the Flow Chart Method (Brown et al 2004) or equivalent. The testing must focus on outfalls of all diameters. Nutrient testing should be conducted on at least 10% of flowing outfalls (as determined during the ORI) annually. 15

IDDE Flow Chart Modified from Brown et al, 2004

Qualifying Criteria for Advanced Programs 4.Specific methods and techniques they use to track a suspect illicit discharge to its source in the storm drain network (Table 3). 17

Qualifying Criteria for Advanced Programs 5.Number and type of illicit discharges that were discovered and actually eliminated each year. 18 Photo credit: Arlington County, DES

Additional Qualifying Criteria In addition, localities will need to document that they are conducting at least two of the following activities to discover and or prevent nutrient discharges to receive credit: 19 1.GIS assessments of storm and sanitary sewer network to identify high risk segments for cross- connections or exfiltration

Additional Qualifying Criteria 2.Dry weather stream monitoring is used to prioritize the stream segments with the highest nutrient and bacteria levels that warrant further investigation 20 3.CCTV inspections, dye testing or other methods to investigate for sewer leaks in problem storm drain systems. 4.Targeted inspection and outreach to businesses and/or industrial facilities subject to high risk for illicit discharges or sewer clogging (e.g. restaurants, car rental agencies, etc.)

Additional Qualifying Criteria 5.Detailed field assessments of the sewer network to identify segments with high risk of nutrient discharge due to exfiltration and/or dry weather overflows (i.e., sewer modeling and metering tools). 21

Q: So I can get credit for my basic IDDE program?? A: No! MS4s that are currently in compliance with their minimum control measure for illicit discharge detection and elimination (IDDE) in their current stormwater NPDES permit get no credit 22 Green Tanks at District of Columbia Firehouses

Zero Credit for Basic IDDE Program MS4s that are currently in compliance with their minimum control measure for illicit discharge detection and elimination (IDDE) in their current stormwater NPDES permit get no credit  Adopt a local ordinance to prohibit illicit discharges to the storm drain system  Develop a storm drain map, including all outfalls 36 inches in diameter or larger  Provide IDDE education and outreach to public employees, businesses and the general public  Use visual indicators to screen outfalls for presence of illicit discharges  Develop and implement appropriate enforcement procedures to correct illicit discharge when they are discovered. 23

Programmatic Credit Design Example Bay Village elects to transition to a nutrient based outfall screening program in two priority catchments within its jurisdiction -- Icky Creek and Filthy Run. Together, the two catchments are 3,600 acres in size, and average 64% urban pervious land. Bay Village documents in its annual MS4 report that it has met or exceeded the program metrics outlined in the report. The nutrient reduction credit for modifying their program is computed as follows. 24

Programmatic Credit Design Example 25 Step 1: Determine the unit area nutrient load for pervious land from CAST or state equivalent, and multiply by Staff determine unit area TN and TP loads are and 0.43 lbs/acre/year, respectively, within their jurisdiction. These are multiplied by the dry weather baseline multiplier of 0.2, which yields 2.09 lbs TN/ac/yr and lbs TP/ac/yr. Step 2: Multiply these unit loads by the qualifying acres of pervious land in Icky Creek and Filthy Run (3,600 acres*64% = 2,304 ac), which yields: 4815 lbs/yr of TN and lbs/yr of TP Step 3: Multiply these loads by the 0.01 to determine final nutrient reduction credit for the program change lbs/yr of TN and 1.98 lbs/yr of TP

Reporting, Tracking and Verification of Advanced Program Credit Localities Typically Submit to States in MS4 Permit Annual Reports Appendix E Outlines the NEIEN Reporting Information Localities eligible for credit in 2015, assuming they meet qualifying conditions (most MS4’s won’t immediately qualify) 26

Reporting, Tracking and Verification of Advanced Program Credit The acres subject to the program credit lapse five years after the first year in which they are reported Additional acres in succeeding years if they elect to target additional storm/sewersheds for intensive nutrient discovery Eventual shift to reporting individual nutrient discharge credits in 2018 Cannot take credit for program and individual credits at same time 27

Management Significance More than a thousand Bay communities are required to have an IDDE program (although very few have nutrient-based outfall screening) Thousand of dry weather overflows occur each year across the Bay but no local incentives to reduce the systematic causes of the problem Enlisting potential new partners in reducing nutrients from the urban sector 28

29 Crediting for Individual Discharges

8 Individual Nutrient Discharges Credited 30 No.Discharge Type N-1Laundry Wash Water N-2Commercial Car Wash N-3Floor Drains N-4Misc. High Nutrient Discharges N-5Sanitary Direct Connection N-6Sewer Pipe Exfiltration N-7Drinking Water Transmission Loss N-8Dry Weather Sanitary Sewer Overflows

Non-Eligible Nutrient Discharges Unexpected nutrient discharges from pipe breaks, spills, leaks and overflows that are reported to the local authority by the public or first responders and require immediate emergency repairs to stop the discharge. Residential car washing Transitory illicit discharges associated with power- washing, dumpster juice, transport accidents, and illegal sewage disposal by boats and RVs. Wet Weather Sanitary Sewer Overflows Catastrophic wet weather sanitary sewer overflows that exceed the sewer design capacity Combined Sewer Overflows * Septic field discharges caused by system failure * 31

The Crediting Approach The guiding principle is that elimination of a discovered nutrient discharge could only be considered as a urban BMP, if they: Are detected and physically eliminated On-site sampling of the discharge that has been eliminated to define one or more of the following parameters -- nutrient concentration, flow rate and duration Subsequent inspections and/or monitoring verify or otherwise confirm that discharge no longer exists

Empirical Approach to Crediting

Data Requirements to Compute the Credits Table 5 Data Requirements to Compute Reduction Credits No.Discharge Type MethodNutrientsFlow Volume Flow Duration N-1Laundry Wash Water1S or DE or ME N-2Commercial Car Wash1SE or ME N-3Floor Drains1SE or ME N-4Misc. High Nutrient Discharges1SE or ME N-5Sanitary Direct Connection1S or DE or ME N-6Sewer Pipe Exfiltration2S or DME N-7 Drinking Water Transmission Loss 2S or DME N-8Dry Weather SSOs3S or DEM KEY: S= SAMPLE, D=Use DEFAULT VALUE, E=ESTIMATE, M= MEASURE 34

N-1: Laundry Washwater Definition: Washwater flows that result in the discharge of washwater into the storm drain system. It may involve a residential situation or a commercial laundry operation. DISCHARGE CHARACTERISTICS Intermittent discharge Enters stream directly through straight pipe Multiple Methods of Discovery Regulated by MS4 Permit Pipe reconnection to eliminate discharge Protocol 1 used to calculate credit Requires measurement or estimation of flow rate Verification involves inspection confirming the reconnection 35

N-2: Commercial Car Wash Definition: Washing of vehicles that results in the discharge of washwater into the storm drains system. It may involve a commercial car wash operation (fixed or mobile). DISCHARGE CHARACTERISTICS Intermittent Multiple Methods of Discovery Regulated by MS4 Permit Pipe reconnection to eliminate discharge Protocol 1 used to calculate credit Requires measurement of nutrient concentration and estimation of flow rate and duration Verification includes: Confirmation inspection after reconnection AND confirmation screening during business hours 36

N-3: Floor Drains Definition: Floor or foundation drains illegally connected to the storm drain system. DISCHARGE CHARACTERISTICS Intermittent Multiple Methods of Discovery Regulated by MS4 Permit Pipe reconnection to eliminate discharge Protocol 1 used to calculate credit Requires measurement of nutrient concentration and estimation of flow rate and duration Verification includes inspection confirming reconnection 37

N-4: Misc. High Nutrient Discharges Definition: This discharge category applies to other non-sanitary, high-nutrient discharges that are discovered during nutrient-based outfall screening. The most common so far has been nutrient-associated cleaning agents used to keep outdoor HVAC systems healthy. If other such discharges are discovered, then direct monitoring is required to establish the credit. 38 DISCHARGE CHARACTERISTICS Intermittent Indirect Entry through an inlet Methods of Discovery: Nutrient source sampling Rooftop inspection Pollution Prevention to eliminate discharge Protocol 1 used to calculate credit Requires nutrient concentration measurement and estimation of flow rate Verification methods are discharge dependent:

N-5: Sanitary Direct Definition: A sewer pipe that is improperly connected to the storm drain system either through a cross-connection or from a straight pipe. This discharge category produces a continuous discharge of raw sewage into the storm sewer system or directly to a stream. 39 DISCHARGE CHARACTERISTICS Continuous Direct Entry to storm sewer or stream Multiple Methods of Detection Regulated by MS4 Permit and/or WW permit Pipe reconnection to eliminate discharge Protocol 1 used to calculate credit Requires measurement of nutrient concentration Verification includes: Confirmation inspection after reconnection AND Outfall screening once a year for at least 3 years

N-6: Sewer pipe Exfiltration Definition: Loss of sewage from sanitary sewer pipes during dry weather through the groundwater matrix to the storm drain system as a result of cracks or leaks in sewer pipes. DISCHARGE CHARACTERISTICS Continuous or Intermittent Multiple Methods of Detection Regulated by NPDES WW permit Multiple Elimination Methods: Slip-lining of Pipes Pipe Replacement Manhole Sealing Protocol 2 used to calculate credit Requires 6 mos of before and after sewer metering to measure flow and estimate conc. 40

N-7: Drinking Water Transmission Loss Definition: The loss of drinking water as it is delivered in pipes to the consumer that reaches the stream through storm drain pipes and/or groundwater migration. DISCHARGE CHARACTERISTICS Continuous Regulated differently by each state Multiple Elimination Methods: –Slip-lining of Pipes –Pipe Replacement –Pipe upgrades Protocol 2 used to calculate credit Requires 6 mos of before and after sewer metering to measure flow Nutrient concentrations derived from CCRs Verification includes: –Flow monitoring at the site of repair and above and below the problem water line for one year 41

N-8: Dry Weather SSOs Definition: A sanitary sewer overflow that occurs during dry weather periods as a function of either a blockage or failure of the sanitary sewer system. DISCHARGE CHARACTERISTICS Transitory Regulated by NPDES WW permit Multiple Elimination Methods: –FOG Reduction Programs –Pretreatment Requirements –Sewer Realignment –Pipe Replacement –Manhole Casing Protocol 3 used to calculate credit 2 years of before and after tracking of the number and flow volume of overflows within the sewershed Verification includes: –See confirmation monitoring above 42

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